Privacy Policy

Version [2.0]. Last updated June 2020.

 

This Privacy Policy

This Privacy Policy (“Privacy Policy”) explains how Alcami Interactive Pty Ltd (ABN 23 600 850
584) (“Alcami Interactive”, “we” or “us”) handles and manages personal information we
collect about you as a:

  • visitor to our website (“Visitor”) whether accessed at alcami.com or alcamiinteractive.com (the “Site”); and/or
  • user of the Alcami Interactive digital video interview platform accessible at alcami.video
    or a subdomain thereof (“Platform”), either as a candidate for a role with one of our
    clients (“Candidate”) or as an employee/agent of one of our current or prospective clients
    (“Client Representative”).

We are bound by and adhere to the Privacy Act 1988 (Cth) and the Australian Privacy
Principles under that Act (“Privacy Act”) and this Privacy Policy.

By using the Site, the Platform and/or providing us with any personal information you agree that
you 16 years of age or older and consent to our collection, use, holding and disclosure of your
personal information, including your sensitive information, in accordance with and as set out in
this Privacy Policy.

 

WHAT PERSONAL INFORMATION WE COLLECT AND HOW

FOR VISITORS

As a Visitor, we collect your personal information when you provide to it us on the Site (i.e.
entering information into a form, contacting us or responding to or recording answers to
questions on the Site) and/or if you otherwise contact us by phone, email or mail. As a Visitor,
we also collect information through the use of cookies (explained in the Cookies
section below).

FOR CANDIDATES

As a Candidate, applying for a role via the Platform or otherwise, we collect:

  • “Account Information”, specifically your full name, email address, phone number and the IP
    address that you use to access the Platform and sometimes a photograph of you (i.e. a still
    frame taken from footage you record when you provide a video response as part of applying
    for a role); and
  • “Candidate Information”, which includes any personal information provided via us or the
    Platform but collected by or on behalf of our client in relation to an application you make
    for a role with one of our clients, including text and audio/video you provide via the
    Platform and notes/annotations, if any, that our client makes about you using or on the
    Platform.

Account Information may be collected directly from you or may be provided to us by our client
where you have applied to that client for a role. If you believe your information has been
provided to us in error or is inaccurate, please contact us using the details in Our
Contact Information below and we will delete or, if appropriate, correct the personal
information we hold about you as Account Information.

We also collect your personal information so that we can contact you if any problems arise in
relation to your use of the Platform.

Candidate Information is collected when, as a Candidate, you respond to interview questions
presented to you. Your responses will be collected and held by the Platform (including text,
sound and/or video data) for and on behalf of our client. Any responses may include written
answers and audio/video recordings that contain sensitive information about you. We collect your
personal information for and on behalf of our clients as Candidate Information in written
answers and audio/video recordings and client notes in any tools or pages included on the
Platform so that our clients, to which you are applying for a role, can:

  • assess the Candidates;
  • shortlist Candidates for roles; and
  • if you are shortlisted, contact you to progress your application.

FOR CLIENT REPRESENTATIVES

As a Client Representative, we collect “Account Information” including your full name, job title,
email address, phone number, physical office address and, in some cases, a profile photo (such
as a social media profile picture). We may collect this information from your employer or your
principal if you are an agent (i.e. from our client) to set up and manage the client’s account
on and your access on their behalf to the Platform and, if necessary, to contact you in relation
to your use of the Platform.

If your company is not a client yet and you are considering using the Platform in your
recruitment process, you may choose to provide your name, company, phone number and email
address to request a personalised demo of the Platform or to contact us with a query. You might
leave your details with us at a conference or event at which Alcami exhibits our product
offering. We collect this information for the purpose of arranging to provide a demo (and
personalising it) for and to you. Similarly, if you contact us by phone, email or mail we will
collect your contact details for the purpose of responding to your query.

FOR VISITORS, CANDIDATES, CLIENTS AND CLIENT REPRESENTATIVES

If you provide us with the personal information of another person, you warrant that you have
obtained their prior consent: (i) for you do so; and (ii) to our collection, use, holding and
disclosure of their personal information in accordance with this Privacy Policy.

 

HOW WE USE YOUR PERSONAL INFORMATION

We use the personal information we collect about you for the purpose of running the Platform and
providing services to our clients, in particular:

  • to verify your identity where this is necessary to protect our clients, Client
    Representatives and/or Candidates;
  • respond to your queries;
  • contact Candidates to request you to respond to interview questions;
  • provide submitted responses of Candidates to clients and Client Representatives;
  • provide tools and pages on the Platform where clients and Client Representatives can make
    notes/annotations, correspond with their colleagues and manage their recruitment activities;
  • notify Candidates of any updates in relation to an application they have submitted or are in
    the process of submitting;
  • provide our services to clients and Client Representatives;
  • for statistical analysis to help us enhance the Platform and better serve our clients and
    Candidates; and
  • for our purposes as permitted or required by law.

 

HOW WE SHARE YOUR PERSONAL INFORMATION

Our related entities and a number of third party service providers support the functionality of
the Platform and we will share your personal information with them to assist us to perform one
or more of the purposes set out in this Privacy Policy and, in particular:

  • to provide live chat and customer support functionality on the Site and the Platform;
  • to send email and SMS communications to Candidates and our clients, as necessary to operate
    the Platform;
  • to provide the ‘request personalised demo’ functionality on the Site; and
  • to support live video-conferencing.

Our third party service providers are headquartered in:

  • Australia;
  • New Zealand;
  • the United Kingdom; and
  • the United States.

While we use these third party tools ourselves (and do not disclose your personal information to
these third parties for their own use), review the privacy and security arrangements of our
third party service providers and control the data stored by our third party services providers,
in some cases it is technically possible for them to access data containing your personal
information. We note that all related entities we share your personal information with, for the
purposes noted in this Privacy Policy, are located in Australia and subject to the Privacy Act.

FOR CANDIDATES

If you are a Candidate, we share your Candidate Information provided via the Platform with the
relevant clients and Client Representatives of those clients to which you are applying. This
includes your interview responses (see the Candidate Information and Interview Content
section below). Clients will also have their own privacy policies and practices for handling
your personal information so you should familiarise yourself with the privacy policies of any
clients to whom you apply via the Platform.

 

HOW OUR CLIENTS USE THE PLATFORM

Our clients are looking to hire employees. Clients may also be recruitment companies that are
looking to find candidates for roles at their clients.

Each of our clients nominate one or more authorised Client Representatives who are able to access
the Platform on behalf of that client. Client Representatives review information provided by
Candidates as part of the process of shortlisting Candidates and, ultimately, selecting which
Candidate(s) will be offered further interviews and/or roles with the client. Client
Representatives may add notes and annotations to a Candidate’s profile, application and/or
interview answers as part of this process and these may constitute personal information using
the tools and pages on the Platform. However, at all times Candidate Information is the
responsibility and under the control of the client. If you have any queries in relation to
Candidate Information, we recommend that you contact the relevant client.

 

CANDIDATE INFORMATION AND INTERVIEW CONTENT

When using the Platform Candidates are prompted to answer questions prepared by the client either
by written or audio/video responses (“Responses”). Reponses that you have written or recorded on
or uploaded to the Platform will be shared with Client Representatives of the relevant client.
We store the Responses on our servers for 12 months then (to the extent they are stored on the
Platform) delete them. However, the client(s) to whom you applied have the option to download
the Responses during this 12-month period and may store them together with any other Candidate
Information they have collected for a longer period. You should read their privacy policy as to
how they process your personal information.

If you are a Candidate and have any queries or requests in relation to the role you are applying
for, the interview process and/or your Responses and/or wish to access your Responses after 12
months from submitting them via the Platform, we suggest that you contact the relevant client
directly. For information about accessing or updating your Candidate Information, please see the
Updating and/or Accessing Your Personal Information section below.

 

MARKETING COMMUNICATIONS

If you are a client or Client Representative, if and as permitted by law we may use your personal
information to contact you with details of products, services or promotions from Alcami
Interactive that we think may be of interest to you. If at any time you decide that you no
longer wish to receive marketing communications from us, you will always have the ability to
unsubscribe.

 

UPDATING AND/OR ACCESSING YOUR PERSONAL INFORMATION

ACCOUNT INFORMATION

We try to keep the personal information of Visitors, Candidates and Client Representatives
up-to-date. However, we ask that you please advise us whenever your personal information changes
(e.g. your get a new phone number or move to a new address). If you are a Candidate or a Client
Representative, you can update some of your personal information by logging into your account on
the Platform. Otherwise, please contact us using the details noted in the Our Contact
Information
section below.

You have the right to request access to your personal information at any time by contacting us,
including for the purpose of asking us to correct or update that information. There is no charge
for making such a request but Alcami Interactive may charge a reasonable fee for responding to a
request. We will respond to your request within 30 days of receiving it. If we cannot fulfil
your request for any reason, we will write back to you and explain why.

CANDIDATE INFORMATION

Candidate Information, including interview content and Responses, is legally and contractually
the responsibility of and is controlled by our clients to which you apply. If you are a
Candidate and wish to update or access personal information that you provided via the Platform
as part of an application for a role with a client (i.e. Candidate Information), including
interview content and Responses (beyond 12 months of submitting them), please contact that
client to update or access this part of your personal information.

 

SECURITY OF YOUR PERSONAL INFORMATION

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a
result, while Alcami Interactive will take all reasonable steps to protect your personal
information, including the use of encryption of data in transit, the nature of the Internet is
such that Alcami Interactive cannot guarantee or warrant the security of any information you
transmit via the Internet.

We also have reasonable security controls in place to protect your personal information once it
reaches us (i.e. is stored on the Platform) including encryption of data at rest, regular
software patching and logging of system access. Your personal information is stored on virtual
private cloud infrastructure physically located in Australia and managed by Amazon Web Services,
Inc.

FOR CANDIDATES

If you are a Candidate, only individuals specifically nominated by the client to which you have
applied are authorised to access your personal information.

 

COOKIES

Information may be collected through the use of “cookies” on our Site and the Platform. Cookies
are small text files that a website can use in order to recognise visitors who revisit a website
so as to facilitate their ongoing access to and use of the site. They enable usage behaviour to
be tracked and aggregate data to be compiled that would facilitate more targeted advertising and
improved content. Typically, cookies involve the assigning of a unique number to the visitor.
You can prevent the use of cookies by setting up your web browser to block them.

 

SALE OF THE BUSINESS

Alcami Interactive reserves the right to transfer your personal information to a third party in
the event of a sale, merger, liquidation, receivership or transfer of all or substantially all
of the assets of our company provided that the third party agrees to adhere to the Privacy Act
and the terms of this Privacy Policy.

 

CHANGES TO THIS PRIVACY POLICY

We may, from time to time, update this Privacy Policy so please ensure you review it periodically
for changes. If any changes are significant or substantial we will either let you know in
writing or post a message to that effect on our Site.

Your continued use of the Platform and/or the Site, requesting our services or the provision by
you of further personal information to us after this Privacy Policy has been revised will be
deemed to be your acceptance of and consent to the revised Privacy Policy.

 

IF YOU HAVE A PRIVACY COMPLAINT

If you wish to make a complaint about an alleged breach of this Privacy Policy or the Privacy Act
by us you can contact us using the contact information in the Our Contact Information
section below. You will need to provide us with sufficient detail regarding your complaint and
any supporting evidence.

Our Privacy Officer will investigate the issue and determine the steps to be taken to resolve the
complaint. We will notify you in writing if we require any additional information and also of
the outcome of the investigation.

If you are not happy with the outcome of our investigation, you may complain to the Office of the
Australian Information Commissioner (“OAIC”) whose contact details can be obtained from the OAIC
website noted below in the Further Information section.

 

OUR CONTACT INFORMATION

Any queries about this Privacy Policy, correction or access requests or privacy complaints should
be addressed to:

Privacy Officer
Alcami Interactive Pty Ltd
Level 3, 223 Liverpool Street, Sydney NSW 2000<
privacy@alcamiinteractive.com
+61 2 9199 5600

 

FURTHER INFORMATION

For further information about the Privacy Act or to make a complaint to the Privacy Commissioner,
please see the website of the OAIC at www.oaic.gov.au.

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